Liechtenstein Disclosure Facility
We were approached by an individual who had received correspondence from the Criminal Investigation section of HMRC. We were instructed by solicitors to provide them with financial information so that they could give legal advice. By reconstituting the financial records of the key offshore entity for a twenty year period and by providing explanations to enquiries and attending meetings with HMRC officers both in the UK and outside of the jurisdiction, we satisfied the interest of HMRC Criminal investigation. This work identified issues with the tax affairs of the individual, who was periodically UK resident but foreign domiciled, and the conclusion we reached was to make a submission under the then available Liechtenstein Disclosure Facility. As a result, the taxation affairs of the individual were settled favourably thereby regularising his tax affairs without the need for a full blown tax investigation by HMRC Fraud Investigation Service (then known as Specialist Investigations).
HMRC In Depth Tax Investigation
Representing an individual and his company under tax investigation for alleged concealment of business revenues and other tax irregularities. Settling the investigation on behalf of the client and satisfying the HMRC Specialist Investigations experienced investigator through a comprehensive analysis of private bank accounts that there was no suppression of business revenues.
HMRC Local Tax Enquiry
A service business was subjected to a full books and records inspection for the second time in five years, the first inspection having resulted in no tax increase. The second inspection demanded business and personal records be delivered to HMRC’s offices. HMRC also wanted to meet the business owner.
Our response was to say these demands were disproportionate and went beyond HMRC’s legitimate powers. HMRC did inspect the business records but at our offices. The remainder of the enquiry was conducted by correspondence and no meeting between HMRC and the business owner took place. This second inspection also resulted in no tax increase.
HMRC COP9 Tax Investigation
We were approached by an individual who had received a letter under Code of Practice 9 alleging HMRC had evidence that undisclosed income and capital gains has been omitted from tax returns.
We made immediate contact with HMRC and arranged an initial meeting at which the client attended. By the strategy we adopted at the meeting, the client was not traumatised by the experience and never had to meet the HMRC officers again.
Our report was scoped in conjunction with HMRC, delivered promptly and the matter concluded with reduced penalties for the fullest co-operation and no adverse publicity for the individual or their family.